Standards and procedures

TNK-BP’s HSE long-term goals are clearly stated in the Code of Business Policies and consist of the following:

• No workplace injuries and occupational diseases,
• No accidents,
• Mitigation of adverse impact on the environment. (These differ slightly from goals stated under “HSE policy”)

Strict compliance with health and safety requirements by all company employees is critical to the success of its business.

In accordance with applicable health, safety and environmental protection (HSE) legislation, TNK-BP aims to reduce the environmental and health impact of its operations by introducing advanced technologies, upgrading equipment, cutting waste and discharges; and by creating a safe working environment in the workplace.

The company will strive to produce quality products that can be used safely by our customers.

The HSE Corporate Standards apply to each and every TNK-BP employee in the course of conducting its business.

Agents and representatives doing business on TNK-BP’s behalf, as well as the company’s partners and customers, consultants and advisors, contractors and suppliers are expected to adhere to these Standards.

TNK-BP recognizes that safe operations depend not only on technically sound plants and equipment, but also on employee competence and their strict compliance with all requirements in the area of health, safety and public health regulations, and ensuring conditions that all company’s operations are performed safely.

TNK-BP will:

1. Observe the requirements of applicable legislation and other normative legal acts in the area of health, safety and environmental protection in countries where the company has its operations;

2. Gradually and persistently tighten requirements in the areas where more rigorous requirements are established by international standards;

3. In the area of occupational safety and health:

- Protect staff against injuries, and company’s assets and facilities against damage by creating healthy and safe working conditions and taking measures for physical protection of the company’s operational facilities to prevent entry by unauthorized persons to such facilities and the possibility of criminal or other unlawful acts;

- Take actions to improve working conditions and industrial safety and to prevent accidents in the workplace and occupational diseases;

- Provide mandatory social insurance of staff against accidents in the workplace and occupational diseases, and ensure compliance with sanitary norms as well as medical treatment and preventive services to staff in accordance with labor safety requirements;

- Provide work permits to those who meet the relevant qualification requirements and do not have medical contraindications for the work concerned;

- Provide employees with safety clothing, safety footwear and other personal protective equipment in accordance with established standards and working conditions, and monitor personal and collective protection equipment availability and its correct application by staff.

4. In the area of industrial safety:

- Within the context of the health and safety management system, set up and regularly verify the efficiency of operational control in company organizations. Ensure efficient use of the findings of behavioral audits, bearing in mind that all company’s employees and company contractors, with whom the relevant agreements are concluded, are obliged to fulfill HSE requirements, and that line managers are accountable for understanding and managing HSE risks;

- Carry out a comprehensive assessment of hazardous factors and risks, develop and carry out appropriate compensatory measures;

- Organize an industrial safety review of buildings and certification of workplaces in respect of working conditions in the company’s operational facilities;

- Ensure that normative legal and technical documents stipulating the rules for safe conduct of work in the relevant workplaces are available in all company operational facilities;

- Ensure the registration of hazardous operational facilities of company’s organizations in the State Register;

- Ensure the drafting and timely revision of Industrial Safety Declarations in companies listed in the Official TNK-BP Group List comprising hazardous operational facilities;

- Carry out diagnostics, testing and certification of installations and technical devices used in hazardous operational facilities. Ensure that the procedure and conditions of use are complied with and that an industrial safety review is conducted on technical devices in hazardous operational facilities belonging to company organizations, listed in the Official TNK-BP Group List;

- Execute risk liability insurance contracts for damage caused by the operation of hazardous operational facilities belonging to company where required by internal law.

5. In the area of the prevention of accidents, injuries and emergency situations:

- Provide supervising authorities with accurate and timely information on accidents and workplace injuries or damage caused to the environment in compliance with the applicable legislation of the countries where the company has its operations;

- Ensure that every accident, incident or workplace injury is internally investigated and recorded, their causes and conditions contributing to their occurrence are analyzed, appropriate preventive measures to remove and prevent them are developed and implemented;

- Develop emergency situation containment and response plans (ERP) and oil, oil products, and produced water emergency spill response plans (ESRP) in TNK-BP organizations, and train employees in responding to accidents and incidents at hazardous operational facilities;

- Contract with professional emergency rescue teams or units for the provision of services or set up similar in-house teams or units within company organizations;

- Provide for financial provisions and material resources for incident containment and response;

- Set up systems for observation, notification, communication and support of actions in the event of accidents in Subsidiaries, listed in the Official TNK-BP Group List;

- Take measures to prevent emergency situations, protect life and health of employees when such situations occur, including the provision of first aid to casualties.

6. In the area of environmental protection:

- Minimize adverse impact of the company’s operational facilities on the environment (the atmosphere, water sources, soil, subsoil).

- Take into account requirements of governmental bodies and public opinion when any operational decision is taken.

- Perform remediation of land contaminated in the course of the company’s operation, carry out soil clean-up on all oil producing land;

- Evaluate environmental risks and take all possible technical and economic measures to mitigate these risks, and make sure that spill prevention and response capabilities are available and adequate;

- Assure the compliance of project solutions with the current Standard; carry out environmental impact assessment for all projects; make environmentally conscious decisions and exercise rigorous supervision over implementation of all scheduled measures to reduce a potential negative impact on the environment;

7. Organize training and certification of employees in the area of health, industrial safety and environmental protection;

8. Suspend and delay, at its own discretion,the resumption of work if there is a potential health and safety threat ;

9. Require that all parties working on the company’s behalf recognize that their actions or inactions can impact onthe company’s image and business, and that they must operate to the company’s standards;

10. Hold all managers within TNK-BP accountable for accomplishing the HSE goals by implementing appropriate HSE behavior, clearly defining HSE roles and responsibilities, providing necessary resources and by measuring, reviewing and continuously improving the company’s HSE performance:

- Develop company business plans with measurable HSE targets, and involve all employees in meeting these targets;

- Present information on both the positive and negative results of its HSE performance;

- Encourage those who contribute to improved HSE performance.

1. LEADERSHIP

Leaders at all levels of the organization are responsible, within their competence, for leading and engaging the workforce in meeting our health, safety, operational integrity and environmental goals and objectives. They should do this in the following ways:

1. By demonstrating their commitment to HSE by personal example and by developing and encouraging employees’ positive attitude to HSE;

2. By improving his/her HSE competencies through learning and practice;

3. By ensuring a two-way communication with employees, contractors and others on HSE issues e.g.;

- Starting every regular meeting by discussing health and safety issues;

- Routinely touring the facilities, monitoring safety compliance and talking openly about HSE issues with workers.

4. By establishing clear HSE goals, roles, responsibilities and performance criteria, and by assigning competent HSE specialists and, where necessary, engaging experts;

5. By assessing their HSE performance against their annual objectives, based on feedback from line management, colleagues and others in the business unit;

6. By promoting the sharing and adopting of HSE lessons learned inside as well as outside their positions;

7. Being responsible for setting up an HSE risk management processes in their units.(Should be bullet 8) By establishing a positive HSE environment and promoting procedures allowing any employee to call for work to be stopped if the employee feels it is unsafe to proceed.

2. INCIDENT INVESTIGATION (ACCIDENTS, INCIDENTS, WORKPLACE INJURIES) AND HSE REPORTING

1. All cases of accidents, incidents or other events causing danger to health and safety, operational integrity and the environment, including near-missesand accidents in the workplace, irrespective of their gravity or the number of victims, must be openly reported to the company line organization and HSE function as well as to supervising authorities, investigated, analyzed and documented according to the company’s internal documents formally enforced throughout the organization and in accordance with the requirements of the relevant normative legal acts;

2. Information gathered in the course of these investigations must be analyzed to identify and monitor trends and develop prevention programs;

3. Lessons learned from investigations must be shared across the company. Upon receipt of such information, staff shall carry out the measures prescribed by internal documents;

4. Individuals may be held liable for deliberately hiding or delaying the submission of information related to the above types of incidents in compliance with labor or other legislation of the countries where the company has its operations.

5. HSE information must be collected, collated and reported monthly in accordance with TNK-BP internal documents.

3. PERSONAL PROTECTIVE EQUIPMENT

Personal protective equipment (PPE) provides the last line of defense in protecting employees from injury and illness in the workplace. It is not a substitute for managing risks through planning, use of engineering controls, etc. However, it is a necessary and important part of the safety management system, and should meet the following basic requirements:

1. All Personal Protective Equipment (PPE) must conform to the requirements established by the company;

2. Managers must ensure that employees performing operations in the company requiring PPE are provided with equipment corresponding to the type and conditions of the work being performed and that this ensures the protection of workers against actual or possible adverse impacts of hazardous operational factors, and they must also ensure that PPE is replaced in accordance with internal documents, regulations and deadlines of replacement and free of charge release Norms.??

3. It is mandatory for company staff to wear the right PPE for the task they are performing and for the working environment in which they are located. Supervisors are accountable to ensure this is followed;

4. Leaders must ensure that all staff receive appropriate training on the correct use of PPE including PPE for specialized professions and specific types of activities;

5. Contractors working on the company’s sites must wear PPE appropriate to the type of work and working conditions. The protective specifications of the PPE used by contactors shall not be inferior to the specifications of PPE provided for by the company’s HSE standards.

4. ALCOHOL AND DRUG ABUSE

All employees have an obligation to observe operational and labor discipline and prevent violations of the health and safety rules and standards established by the company.

1. Leaders will ensure that anyone under alcoholic or narcotic intoxication is not permitted to work;

2. Candidates for jobs and employees must be aware of the company’s Policy concerning storing, distribution and abuse of alcohol and drugs at workplaces and the company’s facilities;

3. Consumption, storing, distribution of drugs is prohibited at any workspace in the company;

4. Sale and consumption of alcohol is prohibited at any workplace or site in the company;

5. Random and scheduled testing of employees and contractors for alcohol and drugs will be implemented at all sites of the company;

6. The company may conduct unannounced searches for drugs and alcohol on company-owned or company-controlled property;

7. If an employee is in need of treatment due to alcohol or drug addiction and this need is confirmed by a medical consultation, the manager shall facilitate:

- Possible granting of scheduled vacation or unpaid days off (no more than 3 months) for the period of the treatment.

- Possible partial or full funding of treatment if it is not covered by social benefits.

The employer will contribute to such funding no more than once per year. All cases shall be reviewed in confidence.

8. An employee implicated in violating this Standard is not eligible for voluntary assistance as described in Clause 7 above.

5. IMPLEMENTATION OF GENERAL REQUIREMENTS TO WORK

No work shall commence until the following conditions are met:

• Risk assessment and safety inductions have been conducted;
• All personnel assigned to perform the work are duly trained and competent to perform the work concerned;
• The necessary safety measures have been taken and employees provided with PPE in accordance with the risk assessment requirements;
• A detailed plan of evacuation from the work location in case of an emergency situation has been thought out in detail;
• Each employee knows that if the work cannot be done safely it must be stopped.

Before conducting work in confined spaces, gas hazardous operations, work involving power units, moving loads with cranes, ground disturbance work in locations where concealed hazards may exist, repair work at an operating facility or hot work in potentially explosive environments, a permit must be obtained (a work permit) that:

1. Defines the scope of work and its timeframe;

2. Identifies all hazards and assesses risk;

3. Identifies all power sources that must be isolated prior to commencement of operations;

4. Establishes control measures to eliminate or mitigate risks;

5. Links the work to other associated work permits or simultaneous operations;

6. Is signed by the responsible person(s);

7. Ensures adequate control over the return to normal operations;

The content of the work permit shall be discussed with all personnel involved with the work at the jobsite immediately before starting work;

Work will be stopped and reassessed for hazards and risks if:

• Job conditions change
• Modifications to the procedure are required
• New personnel become involved in the work

6. ENERGY ISOLATION

A power source is any electrical, mechanical, potential, hydraulic, pneumatic, gravitational, chemical, nuclear, thermal, or other power source that could cause injury. Repair and any other work on equipment that is not related to use of such equipment for its primary purpose cannot proceed until the following requirements are met:

1. All power sources have been isolated from the equipment,

2. The methods of isolation and discharge of stored energy are agreed and executed by competent personnel.

3. Any stored energy is discharged

4. The appropriate caps and blocking devices and (or) warning signs are put in place to ensure the sources are not re-energized until work is completed

5. A test is conducted to ensure the isolation is effective

6. Isolation effectiveness is periodically monitored

7. Caps, blocking devices and warning signs may not be removed and equipment re-energized until all work on the equipment has been completed.

7. GROUND DISTURBANCE AND CONFINED SPACE ENTRY

Ground Disturbance

Ground disturbance includes any man-made cut, cavity, trench or pits in the earth’s surface, formed by earth removal.

1. A ground disturbance work permit shall be issued in which the boundaries of such work are established;

2. A risk assessment of the work shall be completed by a competent person(s) and required safety measures and personal protective equipment shall be identified and workers given special instructions;

3. All underground hazards, i.e. pipelines, electric cables, etc. shall be identified, contained and, if necessary, isolated where workers are present at a ground disturbance site;

4. If the ground disturbance site meets the definition of a confined space, a permit shall be issued for conducting operations in the confined space;

5. During the work, ground movement must be monitored and measures must be taken to prevent its collapse;

6. Measures must be taken to prevent access to the site of personnel not involved in the work.

Confined Space Entry

A confined space is a space that is large enough for personnel to enter; has limited or restricted means of entry or exit; does not have reliable natural ventilation and is not designed for continuous or lengthy human occupancy. Working in a confined space shall include any work inside equipment such as vessels, cisterns, tanks, gas holders etc. as well as in enclosed tunnels, trenches etc.

Any work in a confined space is gas-hazardous and shall be carried out under the following conditions:

1. A risk assessment has been performed, measures have been developed and safety equipment has been identified, including personal protective equipment, and options for carrying out the work without sending people into confined spaces have been examined;

2. A work permit is issued by a person(s) responsible for the performance of the work, agreed with related operational units and the relevant services of the company or relevant Subsidiary specified in the Official TNK-BP Group List;

3. The issue of the work permit is announced and communicated to all relevant personnel under the established procedure;

4. All power sources in the space concerned have been isolated and safely disconnected from all process lines;

5. The gas environment has been tested, producing a result that permits the performance of work within the confined space with subsequent repeat analyses at a frequency defined by the risk assessment;

6. A stand-by person is stationed at the entry to the confined space with the same equipment as the worker in the confined space;

7. A self-contained breathing apparatus shall be worn for protection of the respiratory organs inside the confined space;

8. Measures shall be taken to prevent access to the site by personnel not involved in the work;

9. The evacuation route of the employees from the confined space if required shall be thought out in advance.

8. WORK AT HEIGHT

Work at height is when a worker is at the distance of less than 2 m from open edges at a height of 1.3 m and more.

The following conditions shall be observed when working at height:

· (is this a bullet?) A fixed platform shall be used with a guard or hand rails, technically verified by a competent person(s) or

·A fall preventer shall be used that is capable of supporting at least a 7000 N (700 kg) static load per person and has:

• A special anchor;
• Full body harness using double latch self locking snap hooks at each connection and connected to the anchor
• Synthetic fiber lanyards
• Shock absorber

·A visual inspection of the fall arrest equipment and system is completed prior to each use. If any equipment has been damaged it is to be taken out of service.

·Special instructions to employees assigned to perform work at height.

Work at height may only be performed by employees above 18 years of age who have passed medical examinations, have no contraindications for working at height, possess professional skills, and have been trained and certified in the use of safe work practices.

9. LIFTING OPERATIONS

Lifting operations utilizing cranes, hoists, or other mechanical lifting devices can be carried out under the following conditions:

1. A risk assessment of the planned operations has been completed and the lift method, sling arrangements , measures ensuring safe conduct of the work, and the necessary equipment have been approved by a competent person(s);

2. Crane operators (machine operators) and their assistants, machine operators (crane operators), machine operators (operators) of all lifting devices have been trained and certified and carry with them certificates stating the type and design of crane that they are permitted to operate, and operators of electrical lifting mechanisms have, in addition to this, an electrical safety qualification;

3. Cranes to be operated are provided with registration numbers, certified lifting capacities and dates of the next partial or full technical inspection;

4. Hooking of the load is carried out by a competent person(s) and all slings and cables have been visually inspected for defects before each use;

5. Where it is necessary to lift and move a load using several cranes, a plan or process map is compiled and the work is carried out under the direct supervision of the person responsible for the safe operation of the cranes;

6. The lifting devices have been subjected to a partial or full technical inspection at least 12 months prior to the commencement of operations, and the hoisting devices and packaging have been inspected: slings (with the exception of those rarely used) – at least 10 days prior to the commencement of operations, braces, grapples and packaging – at least a month, and detachable load grabbing devices – prior to being issued for operation;

7. Load does not exceed dynamic and/or static capacities of the lifting equipment;

8. Sites and locations for stockpiling loads are identified and equipped;

9. Safety devices installed on lifting equipment are operational;

10. The person responsible for safe operation of the cranes, the crane operators and riggers have signed to confirm that they are familiar with the plan or the technological regulations;

11. Measures are taken to prevent access to the site by personnel not involved in the work.

10. TRANSPORTATION SAFETY

Vehicle Requirements:

1. All company and contractor vehicles, including forklift trucks, must be fit for the purpose and must have been maintained in safe working condition. Seat belts shall be installed and functional and the vehicle shall be equipped with a first aid kit and fire-extinguisher;

2. Exhaust pipes of vehicles servicing facilities where a build-up of hydrocarbon gases is possible must be fitted with spark arresters;

3. The number of passengers should not exceed the manufacturer’s specification for the vehicle;

4. Loads must be secured and must not exceed manufacturer’s specification and legal limits for the vehicle.

Driver Requirements:

1. Seat belts must be worn by all occupants whenever a vehicle is in motion;

2. Drivers must be appropriately assessed, trained, have the relevant driving license and be medically fit to operate the vehicle;

3. Drivers must not be under the influence of alcohol or drugs, or any other substance or medication that could impair their ability to drive;

4. Headlights shall be on at any time, day and night, when driving in populate areas and should be on in all areas between September 15 and April 15 ;

5. Mobile phones or other two-way communication devices must not be used by the driver while operating the vehicle.

11. CONTRACTOR MANAGEMENT

Contractors are one of the key factors in the company’s HSE performance. The company will employ the “one workforce” concept whereby employees and contractors alike are expected to observe the company’s common HSE standards (in the event that relevant terms and conditions are incorporated in contracts with company contractors). Procedures and programs will be developed to ensure structured and managed implementation of this standard.

TNK-BP will actively assess the capabilities of Contractors to provide production related services safely for the company.

TNK-BP will work with contractors to ensure that HSE expectations are clear and mutually aligned, that contractors conduct assessments of the HSE risks arising in their scopes of work, and that they understand such risks and have taken appropriate steps to eliminate and/or mitigate these risks in delivering these scopes within an agreed time frame.

TNK-BP will monitor contractor performance and coordinate with contractors, ensuring that they identify and eliminate gaps in meeting HSE expectations and standards. TNK-BP intends to ensure that contractors comply with company HSE expectations by the following means:

1. Establishing appropriate criteria for pre-selection of contractors (so-called pre-qualification), final selection and retention criteria, including a system for ensuring their compliance and prohibiting contractors from doing the work they have not been pre-qualified for;

2. Contracts with contractors will include conditions on fulfilling the HSE expectations;

3. Hazards and risks associated with contractor activities must be identified and managed and information on them disseminated;

4. Interaction between the company and contractors and the organization of effective management of these processes;

5. Identifying and agreeing performance indicators, standards and targets;

6. For joint ventures and alliances where the company has only a financial involvement and does not contribute other resources for the performance of business operations the company intends to exert the maximum possible influence on partners to ensure that they comply with this Standard;

This Standard applies to all production related work conducted at the company’s facilities, as well as to operations in which the contractor fulfills production related work outside the company’s facilities.

12. EMERGENCY MEDICAL RESPONSE

TNK-BP organizes medical emergency response in case of industrial accident or acute illness at the workplace for the following purposes:

· To preserve the life and health of company employees;

·To minimize the consequences of acute diseases and work related accidents to employees carrying out their work duties. ·To promote final recovery of a company employee.

For the purposes of this Standard emergency medical aid is conventionally divided into 4 levels from the moment when the casualty was found or asked for medical help:

• Level 1 –on-site first aid provided by “first aid attendants” — no later than 4 minutes;
• Level 2 – emergency medical care provided by personnel of the Health Units and/or Ambulance Teams – no later than an hour;
• Level 3 – qualified medical care in hospitals – from 4 to 6 hours;
• Level 4 – medical care provided in a specialized medical institution within 24 hours.

For the organization of these medical emergency response tasks, it is necessary to:

1. Appoint in the subsidiaries, listed in the Official TNK-BP Group List (Subsidiaries), a person responsible for the organization of emergency medical care;

2. Develop and approve a plan of emergency medical evacuation and interaction of medical staff with fire fighting units, gas rescue teams and other emergency services;

3. Estimate the required quantity of «first aid attendants» among TNK-BP staff and hold training exercises in first aid provision at least once a month;

4. Medical personnel, participating in medical emergency response, must be certified, have practical skills in medical emergency care provision and attend annual training;

5. Fit all health units and all medical vehicles at the company’s industrial facilities with necessary medical equipment, operational communications and office equipment;

6. Equip production facilities, company vehicles and offices with required stock medical aid kits, and, if necessary, eye wash stations;

7. Organize medical emergency care provision for contractor staff, working at the company facilities.

13. EMERGENCY PREVENTION AND RESPONSE

The crisis and emergency management system is a system of interaction between various company units to manage the company’s activities in the event that various incidents, accidents, events and other emergencies arise.

TNK-BP shall organize a system for managing activities in emergency and crisis situations to ensure a prompt response, to prevent escalation, to protect its reputation and ensure the operational processes are not interrupted, as well as to mitigate the consequences and damage caused by the emergency or crisis situation.

Achieving these aims is a precondition for fulfillment by the company of its commitments to superior financial performance and to protecting partners, employees, the public and the environment.

The basic incident response strategy and the provision of effective support by management are underpinned by the following priorities:

1. Protection of people;

2. Protection of the environment;

3. Protection of property;

4. Protection of the interests of the business, including reputation.

To ensure that emergency prevention and response measures are consistent and effective, the company and its subsidiaries shall set up a specialized centralized emergency response system defining the basic interactions between the company and subsidiaries and providing regular training sessions.

14. ENVIRONMENT

TNK-BP adopts the following guiding principles and objectives in its operations:

1. Concerning air protection, the company shall:

- Carry out inventory and monitoring of polluting emission sources including all sources of greenhouse gas emission;

- Eliminate continuous flaring of associated gas, unsanctioned discharge and technological losses of hydrocarbons;

- Install hydrocarbon vapor recovery systems, introduce other systems and processes to reduce discharge rate.

2. To preserve biodiversity, the company shall:

- Strive to avoid operating in the areas of protected species of plants and animals, in ecologically sensitive areas, during periods of plant vegetation, wild animals breeding and migration seasons; or take all reasonable steps to minimize the impact when operations in a specific season or territory are unavoidable;

- Strive to prevent the creation of permanent and impassible obstacles in the form of linear structures for the migration of wild animals;

- Implement all possible measures to prevent or minimize the impact of the company’s employees on wildlife; supervise delivery.

3. To control and protect water resourcse, the company shall:

- Minimize consumption of fresh water by using, among other methods, recirculation and water saving technologies extensively;

- Exclude contaminated waste water discharge to surface-water bodies and land;

- Carry out engineering works in water protection areas in a way which will exclude water contamination;

- Monitor water intake, discharge and consumption levels on a regular basis to improve water management performance;

- Perform continuous monitoring of waste, surface and underground water to assure adequate control and lower level of contamination.

4. Concerning land protection the company shall:

- Optimize land use patterns on land plots allocated for long-term and short term use in order to reduce industrially affected acreage;

- Avoid operating in traditional habitation areas of the native population, sites of natural, archeological and cultural value, as well as specially protected territories; minimize environmental impact when operations in those areas are unavoidable;

- Develop and implement measures to prevent soil erosion and contamination;

- Mitigate landscape exposure to pipelines and infrastructure construction by introducing special communications corridors.

5. For subsoil protection the company shall:

- Honor requirements delineated by License agreements during the production process;

- Apply production technologies minimizing subsoil contamination and disturbance.

6. Concerning waste management the company shall:

- Apply predominantly technologies that minimize waste generation and provide for its utilization in all business areas;

- Organize persistent liquidation of the unauthorized landfills and clean-up of sludge pits, assure the elimination of unauthorized waste disposal in the future;

- Undertake regular waste inventory and control their utilization by contractors.

15. REMEDIATION AND DECOMMISSIONING

1. TNK-BP will decommission and/or remediate retired assets;

2. TNK-BP will remediate environmental impacts to land and water created or inherited by TNK-BP;

3. TNK-BP will ensure the systematic development of designs and implementation of remediation and decommissioning based on an assessment of risk and remediation and decommissioning priorities;

4. Remediation and decommissioning will be performed based on designs and/or procedures duly approved by the company and government regulatory bodies;

5. A system of controls and assurance for the remediation and decommissioning activities will be implemented in accordance with requirements of the company’s standards and regulations.

6. Remediation will be carried out utilizing the best available technology, selected based on economic, climate, and geographical factors.

7. TNK-BP gives preference to waste minimization, recycling and decontamination rather than to the options of waste storage and ground disposal;

8. TNK-BP will ensure that qualified contractors are selected in accordance with the established internal procedures and will control contractor performance at all stages of implementation of remediation and decommissioning projects;

9. Long-term random monitoring of remediation sites will be performed after completion of remediation in order to assess the condition of the remediated areas and to update remediation designs accordingly;

10. Perform all remediation and decommissioning work in strict compliance with governmental standards and regulations, as well as standards and other internal documents of the company.

16. STANDARDS IMPLEMENTATION AND COMPLIANCE

Implementation of HSE Standards is mandatory for the entire company.

Priorities in implementing standards in each specific Business Unit or Performance Unit will depend on:

1. The operational risk profile;

2. Local and federal regulatory requirements.

TNK-BP managers are accountable for putting in place the required documentation and defining processes for each Standard, for personnel training, for ensuring continuous progress towards the company’s HSE goals and for ensuring effective enforcement of these Standards.

TNK-BP ensures that effective control over the compliance with the Standards is carried out. This is achieved by creating an efficient system of control based on respective organizational, human, material, technical, and financial resources. Implementation of the Standards will be audited in order to measure compliance.

TNK-BP encourages standardization of programs, work processes and procedures in operational facilities and Business Units, and also the transfer and introduction of advanced and efficient practices.